Matter 4 Statement Housing
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September 2016 | JR | CAM.0970 DACORUM BOROUGH COUNCIL SITE ALLOCATIONS DPD EXAMINATION IN PUBLIC MATTER 4 STATEMENT HOUSING LAND SOUTH-EAST OF HOMEFIELD, BOVINGDON ON BEHALF OF TAYLOR WIMPEY TOWN & COUNTRY PLANNING ACT 1990 (AS AMENDED) PLANNING AND COMPULSORY PURCHASE ACT 2004 Pegasus Group Suite 4 | Pioneer House | Vision Park | Histon | Cambridge | CB24 9NL T 01223 202100 | W www.pegasuspg.co.uk Birmingham | Bracknell | Bristol | Cambridge | Cirencester | East Midlands | Leeds | Liverpool | London | Manchester ©Copyright Pegasus Planning Group Limited 2016. The contents of this document must not be copied or reproduced in whole or in part without the written consent of Pegasus Planning Group Limited Taylor Wimpey Land south-east of Homefield, Bovingdon Site Allocations DPD – Matter 4 Statement CONTENTS: INTRODUCTION 1 QUESTION 2 1 QUESTION 3 3 QUESTION 4 3 QUESTION 14 4 APPENDICES (BOUND SEPARATELY): APPENDIX 1: GREEN BELT REVIEW STAGE 1 – MAIN REPORT AND RELEVANT EXTRACTS; SKM, NOVEMBER 2013 APPENDIX 2: LANDSCAPE AND VISUAL APPRAISAL AND GREEN BELT REVIEW; CSA, MARCH 2015 September 2016 | JR | CAM.0970 Taylor Wimpey Land south-east of Homefield, Bovingdon Site Allocations DPD – Matter 4 Statement Introduction 1.1 These representations are prepared on behalf of Taylor Wimpey which has land interests in land at Homefield, Bovingdon. Taylor Wimpey is promoting the site as an omission site for inclusion in the Site Allocations Development Plan Document (DPD) and has made a series of representations to that document, accompanied by technical evidence in support of the allocation of the site. 1.2 This Matter 4 statement should be read in conjunction with the Matter 6 Statement also submitted in support of the site. Q2. Specifically, should more housing be allocated and if so would this be possible prior to the completion of the Green Belt review? 1.3 More housing should be allocated. The Place Strategy for Bovingdon does not adequately provide for the overall Core Strategy target of 130 dwellings in the village during the plan period. The single allocation at site LA6 (Chesham Road) has a theoretical capacity for only 60 dwellings (discussed further below in relation to Inspector’s Question 4) leaving a further 70 dwellings to be identified in Bovingdon to accord with the Place Strategy and the spatial distribution of housing set out in the Core Strategy. Taylor Wimpey consider the Site Allocations DPD is therefore unsound as it cannot be considered effective. The allocation of additional suitable sites in Bovingdon, such as land south-east of Homefield, offers a remedy to this soundness issue. 1.4 Aside from the housing numbers, other Core Strategy objectives, such as those to provide a high level of affordable housing as well as additional open space, are also at risk of not being met. The extent to which a single allocated site can achieve these (particularly where there are concerns that the full number of allocated dwellings cannot be comfortably met) is naturally limited, and an additional allocation will go some way further towards meeting these objectives in Bovingdon. 1.5 It is therefore necessary for the Site Allocations DPD to allocate additional land in Bovingdon to ensure the objectives of the Place Strategy can achieved. 1.6 It is considered that additional housing can be allocated prior to the completion of the Green Belt Review particularly as certain sites have been subject to more detailed consideration through Stage 1 of the Green Belt Review (main report and September 2016 | JR | CAM.0970 Page | 1 Taylor Wimpey Land south-east of Homefield, Bovingdon Site Allocations DPD – Matter 4 Statement relevant extracts at Appendix 1). Land south-east of Homefield, referred to within the Stage 1 Review as ‘D-SS2 – Land at southeast edge of Bovingdon (GB13) at Homefield, off Green Lane’, is identified as one of only two sub- sections of Green Belt in Dacorum borough which least fulfil the purposes of Green Belt. Paragraph 8.3.3 of the Green Belt Review states that “Assessed in isolation this land [site D-SS2] makes a limited or no contribution towards checking sprawl, preventing merging or maintaining local gaps. The sub- area makes a relatively limited contribution to the primary functions of the Green Belt”. 1.7 A study by CSa at Appendix 2 provides further evidence that the site performs a limited role in terms of the Green Belt functions. Chapter 6 of the study considers parcels around Bovingdon for their suitability for release from the Green Belt; paragraph 6.8 advises in respect of land south-east of Homefield that: “This area is well contained in views from the wider area and development would not encroach particularly on the adjoining countryside. In addition, development in this location would not impact on any known heritage assets; contribute to coalescence; and a planned release of land could be accommodated without resulting in urban sprawl. Accordingly, growth in this direction would not significantly impact on the objectives of the Green Belt” 1.8 The findings of the Stage 1 Green Belt Review and the CSa study therefore show that land south-east of Homefield makes a limited contribution to the functions of the Green Belt and is suitable for release at this stage. 1.9 Further justification of the appropriateness of the site can be found in the Call for Sites submission which is attached at the appendix of our Matter 6 statement. 1.10 To ensure the soundness of the Site Allocations DPD it is recommended that land south-east of Homefield is allocated in order to provide an effective means of fully realising the Place Strategy and Core Strategy objectives for Bovingdon. September 2016 | JR | CAM.0970 Page | 2 Taylor Wimpey Land south-east of Homefield, Bovingdon Site Allocations DPD – Matter 4 Statement Q3. In the light of Government’s stated objective in paragraph 47 of the National Planning Policy Framework of boosting significantly the supply of housing, should the Council be seeking to constrain the release of the Local Allocations? If so, what is the rationale for this? 1.11 The Council should not be seeking to constrain the release of the Local Allocations. The Local Allocations comprise six sites but clearly there is potential at this stage to allocate additional sites beyond those Local Allocations given the soundness concerns raised by Taylor Wimpey and other representors. This would also assist the Council in meeting increased housing needs which have emerged through the Strategic Housing Market Assessment which was released after the adoption of the Core Strategy and better reflects the Objectively Assessed Needs of the borough. Land south-east of Homefield is one site which can assist in this. Q4. Is it assumed that all sites, both commitments and allocations, will be developed during the Plan period? Are all of these sites likely to be developed? What account is taken of windfalls? What rate of windfall development is anticipated over the Plan period? 1.12 Site LA6 does not realistically have the capacity to accommodate the full 60 dwellings without resorting to artificially increased densities and building heights or the provision of minimal public open space. As such it cannot be assumed that the allocated site will be developed for the number of units allocated during the Plan period. As set out in our response to Inspector’s Question 2, this necessitates the allocation of additional land in Bovingdon. 1.13 The approach to windfall raises soundness concerns, since of the 130 dwelling target for Bovingdon in the Core Strategy, only 60 are to come forward through allocated sites leaving a further 70, or 54% of the total, to come forward through windfall. The plan is therefore not positively prepared since it does not make proper provision for meeting the full identified target for Bovingdon. This heavy reliance on windfall sites means it will be difficult to achieve the Core Strategy objectives of providing a high level of affordable housing as well as additional open space. Many windfall sites are small in scale and therefore may not be required to provide affordable housing under the 10-dwelling threshold set by Government, and may not be able to contribute significant amounts of public open space. Larger allocated sites offer better opportunities to achieve these objectives. Allocation of land south-east of Homefield will therefore help to ensure that the Plan is positively prepared. September 2016 | JR | CAM.0970 Page | 3 Taylor Wimpey Land south-east of Homefield, Bovingdon Site Allocations DPD – Matter 4 Statement Q14. Is the type and size of housing provided/planned meeting/likely to meet the needs of the area? 1.14 No. As set out above, the Plan’s heavy reliance on windfall sites risks a smaller number of affordable homes coming forward through the Plan period. Therefore, the type of housing planned is unlikely to meet the needs of the area. Land south-east of Homefield can deliver 35% affordable housing (up to 61 units) in accordance with Core Strategy Policy CS19. Allocation of the site will better ensure that the Plan is effective in terms of delivery of affordable housing. September 2016 | JR | CAM.0970 Page | 4 Taylor Wimpey Land south-east of Homefield, Bovingdon Site Allocations DPD – Matter 4 Statement APPENDIX 1 Green Belt Review Stage 1 – Main Report and Relevant Extracts SKM, November 2013 September 2016 | JR | CAM.0970 Taylor Wimpey Land south-east of Homefield, Bovingdon Site Allocations DPD – Matter 4 Statement APPENDIX 2 Landscape and Visual Appraisal and Green Belt Review CSa, March 2015 September 2016 | JR | CAM.0970 GREEN BELT REVIEW PURPOSES ASSESSMENT Prepared for Dacorum Borough Council, St Albans City and District Council and Welwyn Hatfield Borough Council FINAL REPORT November 2013 Green Belt Review: Purposes Assessment (Prepared for Dacorum Borough Council, St Albans City and District Council and Welwyn Hatfield Borough Council) FINAL REPORT November 2013 Sinclair Knight Merz New City Court 20 St Thomas Street London SE1 9RS United Kingdom Tel: +44 (0)20 7939 6100 Fax: +44 (0)20 7939 6103 Web: www.globalskm.com COPYRIGHT: The concepts and information contained in this document are the property of Sinclair Knight Merz (Europe) Limited (SKM).